Here is your NYSE Governance Services update on the 2014 proxy season No-Action Letters. You will receive a weekly No-Action Letters Summary Alert for the 2014 proxy season.
The SEC has accepted 29 No-Action requests and denied 8 of the 57 No-Action requests during the month of February, 2014. The remaining 20 No-Actions were withdrawn by the proponents.
For all 2014 meetings, the SEC has accepted 84 No-Action requests and denied 41 of the 167 No-Action requests, while 41 proposals were withdrawn by the proponents and with one proposal, the Company has determined that it will include the proposal in its 2014 Proxy Materials. Of the 84 accepted, twenty two were accepted on the basis that the proponent failed to respond to notice of defects. Of the 41 denied, 23 were denied where the request for exclusion was that proposal was materially false or misleading. John Chevedden was the leading proponent of shareholder proposals with a total of 19 proposals, followed by Kenneth Steiner with 13 and Qube Investment Management Inc. with 12 proposals.
If you have any questions, please contact Steve Walsh at 212.656.4519 or your Corporate Actions & Market Watch Specialist at 212.656.5414.
| Recent No-Action Letters | |||||
| Company | Filing Date | Proposal Category | Proponent | Status | SEC Filing |
| Intel Corporation (INTC) | February 21, 2014 | Majority Voting | Eric Rehm and Mary Geary | Proponent Withdraws |  NO ACT |
| JPMorgan Chase & Co. (JPM) | February 21, 2014 | Miscellaneous | American Baptist Home Mission Society | Proponent Withdraws | NO ACT |
| Mondelez International, Inc. (MDLZ) | February 21, 2014 | Environmental | Domini Social Investments and The Green Century Equity Fund | Proponent Withdraws | NO ACT |
| AT&T Inc. (T) | February 21, 2014 | Miscellaneous | Neil Maizlish | SEC Accepts | NO ACT |
| Wal-Mart Stores, Inc. (WMT) | February 21, 2014 | Call Special Meeting | James McRitchie | Proponent Withdraws | NO ACT |
| JPMorgan Chase & Co. (JPM) | February 20, 2014 | Independent Chair | Bartlett Naylor | Proponent Withdraws | NO ACT |
| JPMorgan Chase & Co. (JPM) | February 20, 2014 | Miscellaneous | Sisters of Charity of Saint Elizabeth, et al. | Proponent Withdraws | NO ACT |
| AT&T Inc. (T) | February 20, 2014 | Miscellaneous | New York State Common Retirement Fund; Louise Rice; Sarah Nelson; Tamara Davis, John Silva and Shana Weiss | Proponent Withdraws | NO ACT |
| Entergy Corporation (ETR) | February 11, 2014 | Environmental | New York State Common Retirement Fund | SEC Denies | NO ACT |
| Mondelez International Inc. (MDLZ) | February 11, 2014 | Compensation - CEO Pay Ratio | Qube Investment Management Inc. | SEC Accepts | NO ACT |
| No-Action Letters by Month: 2014 Proxy Season | |||||||||
| |||||||||
| Filing Month | No-Action Requests | Accepted by SEC | Denied by SEC | Withdrawn | Others | ||||
| October, 2013 | 2 | 1 | 1 | ||||||
| November, 2013 | 4 | 4 | |||||||
| December, 2013 | 18 | 7 | 4 | 6 | 1 | ||||
| January, 2014 | 86 | 44 | 28 | 14 | |||||
| February, 2014 | 57 | 29 | 8 | 20 | |||||
| Grand Total | 167 | 84 | 41 | 41 | 1 | ||||
| No-Action Letters by Category: 2014 Proxy Season | |||||||||
| |||||||||
| Category | No-Action Requests | Accepted by SEC | Denied by SEC | Withdrawn | Others | ||||
| Accelerated Vesting | 4 | 2 | 1 | 1 | |||||
| Call Special Meeting | 11 | 8 | 1 | 2 | |||||
| Capital Structure | 8 | 7 | 1 | ||||||
| Compensation | 9 | 7 | 2 | ||||||
| Compensation - CEO Pay Ratio | 9 | 8 | 1 | ||||||
| Compensation - Gross-ups | 1 | 1 | |||||||
| Cumulative Voting | 2 | 1 | 1 | ||||||
| Declassify the Board | 1 | 1 | |||||||
| Director Independence | 2 | 2 | |||||||
| Election of Directors | 1 | 1 | |||||||
| Employment Rights | 1 | 1 | |||||||
| Environmental | 17 | 3 | 5 | 9 | |||||
| Equity Compensation | 9 | 5 | 3 | 1 | |||||
| Human Rights | 8 | 7 | 1 | ||||||
| Independent Chair | 15 | 4 | 7 | 4 | |||||
| Lobbying | 7 | 3 | 4 | ||||||
| Majority Voting | 11 | 7 | 2 | 2 | |||||
| Mergers and Acquisitions | 1 | 1 | |||||||
| Miscellaneous | 27 | 12 | 1 | 14 | |||||
| Political Spending | 7 | 5 | 1 | 1 | |||||
| Proxy Access | 2 | 2 | |||||||
| Voting Rules | 2 | 1 | 1 | ||||||
| Written Consent | 12 | 1 | 11 | ||||||
| Grand Total | 167 | 84 | 41 | 41 | 1 | ||||
| No-Action Letters by Exclusion Basis: 2014 Proxy Season | |||||||||
| |||||||||
| Exclusion Basis | No-Action Requests | Accepted by SEC | Denied by SEC | Withdrawn | Others | ||||
| 14a-8(b)(2)(i): Intends to continue to hold the securities | 1 | 1 | |||||||
| 14a-8(b): Eligible record holder of the securities | 17 | 7 | 7 | 3 | |||||
| 14a-8(e)(2): Proposal received after the deadline | 5 | 3 | 2 | ||||||
| 14a-8(f): Shareholder fails to respond to notice of defects | 23 | 22 | 1 | ||||||
| 14a-8(h)(3): Failed to attend previous meeting or present the proposal | 1 | 1 | |||||||
| 14a-8(i)(1): Improper under state law | 3 | 1 | 2 | ||||||
| 14a-8(i)(10): Substantially implemented | 26 | 8 | 6 | 12 | |||||
| 14a-8(i)(11): Duplication | 11 | 6 | 1 | 4 | |||||
| 14a-8(i)(12): Resubmissions | 5 | 3 | 1 | 1 | |||||
| 14a-8(i)(13): Specific amount of dividends | 4 | 4 | |||||||
| 14a-8(i)(2): Causes company to violate law | 1 | 1 | |||||||
| 14a-8(i)(3): Materially false or misleading statements | 31 | 4 | 23 | 3 | 1 | ||||
| 14a-8(i)(4): Personal grievance or special interest | 2 | 1 | 1 | ||||||
| 14a-8(i)(7): Deals with ordinary business operations | 29 | 15 | 1 | 13 | |||||
| 14a-8(i)(9): Conflicts with company | 1 | 1 | |||||||
| 14a-8(i)(9): Conflicts with company's proposal | 7 | 7 | |||||||
| Grand Total | 167 | 84 | 41 | 41 | 1 | ||||
| No-Action Letters by Proponent: 2014 Proxy Season | |||||
| Proponent | No-Action Requests | Accepted by SEC | Denied by SEC | Withdrawn | Others |
| Alex Friedmann | 1 | 1
Miscellaneous |
|||
| Amalgamated Bank's LongView Large Cap 500 Index Fund | 1 | 1
Compensation - CEO Pay Ratio |
|||
| American Baptist Home Mission Society | 1 | 1
Miscellaneous |
|||
| Bartlett Naylor | 1 | 1
Independent Chair |
|||
| Bernice Schoenbaum | 1 | 1
Miscellaneous |
|||
| Boston Common Asset Management | 1 | 1
Environmental |
|||
| C. Francois Swanepoel | 1 | 1
Independent Chair |
|||
| Calvert Social Index Fund and the Calvert VP S&P 500 Index Portfolio | 2 | 1
Miscellaneous |
1
Miscellaneous |
||
| Carol A. Reisen | 1 | 1
Environmental |
|||
| Central Laborers' Pension Fund | 1 | 1
Political Spending |
|||
| Christian Brothers Investment Services, Inc.; the Benedictine Sisters of Mount St. Scholastica; The Granary Foundation; the Board of Pensions of the Presbyterian Church (USA); Providence Trust; the School Sisters of Notre Dame, Central Pacific Province; C | 1 | 1
Miscellaneous |
|||
| Christopher Reynolds Foundation, the Unitarian Universalist Association and Friends Fiduciary Corporation | 1 | 1
Lobbying |
|||
| Christopher S. McElroy Irrev Trust U/A | 1 | 1
Environmental |
|||
| City of Philadelphia Public Employees Retirement System | 1 | 1
Independent Chair |
|||
| Congregation of the Sisters of Charity of the Incarnate Word, San Antonio and First Affirmative Financial Network, LLC. | 1 | 1
Political Spending |
|||
| Connecticut Retirement Plans and Trust Funds | 1 | 1
Independent Chair |
|||
| CtW Investment Group | 2 | 1
Lobbying |
1
Proxy Access |
||
| Dale Wannen | 1 | 1
Human Rights |
|||
| Daniel Altschuler | 1 | 1
Independent Chair |
|||
| Daniel Ballin, Mia MacColin | 1 | 1
Environmental |
|||
| David Watt | 1 | 1
Independent Chair |
|||
| Domestic and Foreign Missionary Society ofthe Episcopal Church | 1 | 1
Human Rights |
|||
| Domini Social Investments and The Green Century Equity Fund | 1 | 1
Environmental |
|||
| Donald Gilson | 1 | 1
Compensation |
|||
| Elena Baum | 1 | 1
Environmental |
|||
| Elton Shepherd | 2 | 2
Equity Compensation (2) |
|||
| Eric Rehm and Mary Geary | 1 | 1
Majority Voting |
|||
| Estella Salvatierra | 1 | 1
Miscellaneous |
|||
| GE Stockholders' Alliance, the Leo A. Drey Revocable Trust and Olga P. Strickland | 1 | 1
Environmental |
|||
| Harold G. Plog | 1 | 1
Miscellaneous |
|||
| Harrington Investments, Inc. | 1 | 1
Miscellaneous |
|||
| International Brotherhood of Electrical Workers Pension Benefit Fund | 2 | 1
Equity Compensation |
1
Equity Compensation |
||
| Jack and Ilene Cohen | 1 | 1
Compensation |
|||
| James Diehl | 1 | 1
Miscellaneous |
|||
| James McRitchie | 4 | 1
Call Special Meeting |
2
Independent Chair (1) Proxy Access (1) |
1
Call Special Meeting |
|
| James McRitchie and Myra K. Young | 4 | 3
Call Special Meeting (1) Majority Voting (1) Voting Rules (1) |
1
Independent Chair |
||
| James Penzak | 5 | 5
Capital Structure (5) |
|||
| Jing Zhao | 1 | 1
Human Rights |
|||
| John C. Harrington | 1 | 1
Miscellaneous |
|||
| John Chevedden | 19 | 11
Accelerated Vesting (1) Call Special Meeting (5) Independent Chair (2) Majority Voting (3) |
8
Equity Compensation (2) Independent Chair (3) Voting Rules (1) Written Consent (2) |
||
| Joyce Loving | 1 | 1
Miscellaneous |
|||
| Kenneth Steiner | 13 | 4
Call Special Meeting (1) Cumulative Voting (1) Director Independence (1) Equity Compensation (1) |
8
Call Special Meeting (1) Equity Compensation (1) Majority Voting (1) Written Consent (5) |
1
Call Special Meeting |
|
| Leonid Zhevelyuk | 1 | 1
Capital Structure |
|||
| Margot Cheel and Park Foundation, Harrington Investments Inc. on behalf of Sarah Nelson | 1 | 1
Miscellaneous |
|||
| Margrit Vanderryn | 1 | 1
Political Spending |
|||
| Margrit Vanderryn, Francine Allen and Vanderryn International Corporation | 1 | 1
Environmental |
|||
| Marie-Claude Hessler-Grisel | 1 | 1
Miscellaneous |
|||
| Martin Harangozo | 1 | 1
Cumulative Voting |
|||
| Massachusetts Laborers' Pension Fund | 1 | 1
Miscellaneous |
|||
| Missionary Oblates of Mary Immaculate, the Sisters of St. Francis of Philadelphia, the American Baptist Home Mission Society, Neva Goodwin, the Sisters of St. Dominic of Caldwell New Jersey, the Needmor Fund and the Sisters of Charity of Saint Elizabeth | 1 | 1
Miscellaneous |
|||
| Myra K. Young | 2 | 2
Majority Voting (1) Written Consent (1) |
|||
| Nathan Cummings Foundation | 1 | 1
Miscellaneous |
|||
| National Center for Public Policy Research | 2 | 1
Political Spending |
1
Environmental |
||
| National Center for Public Policy Research and James Mackie | 1 | 1
Political Spending |
|||
| Neal Renn | 1 | 1
Miscellaneous |
|||
| Neil Maizlish | 2 | 1
Miscellaneous |
1
Miscellaneous |
||
| New York City Employees' Retirement System , the New York City Fire Department Pension Fund , the New York City Teachers' Retirement System , the New York City Police Pension Fund and the New York City Board of Education Retirement System | 1 | 1
Independent Chair |
|||
| New York State Common Retirement Fund | 4 | 2
Compensation (2) |
1
Environmental |
1
Lobbying |
|
| New York State Common Retirement Fund; Louise Rice; Sarah Nelson; Tamara Davis, John Silva and Shana Weiss | 1 | 1
Miscellaneous |
|||
| NorthStar Asset Management, Inc. Funded Pension Plan | 1 | 1
Political Spending |
|||
| Pamela Morgan | 1 | 1
Environmental |
|||
| Park Foundation | 1 | 1
Environmental |
|||
| Patricia R. Sax | 1 | 1
Lobbying |
|||
| Patrick Missud | 1 | 1
Lobbying |
|||
| Peter W. Lindner | 1 | 1
Human Rights |
|||
| Province of St. Joseph of the Capuchin Order | 1 | 1
Environmental |
|||
| Qube Investment Management Inc. | 12 | 12
Compensation (2) Compensation - CEO Pay Ratio (8) Director Independence (1) Election of Directors (1) |
|||
| Richard A. Albert | 1 | 1
Miscellaneous |
|||
| Robert Fredrich | 1 | 1
Mergers and Acquisitions |
|||
| Roberto Rodriguez Velez, Chamir Highley Melendez, Jerom L. Garffer | 1 | 1
Capital Structure |
|||
| Roy R. Sykes | 1 | 1
Equity Compensation |
|||
| Seth Heald | 1 | 1
Miscellaneous |
|||
| Sisters of Charity of Saint Elizabeth, et al. | 1 | 1
Miscellaneous |
|||
| Sisters of St. Francis of Philadelphia, The Needmor Fund, the Missionary Oblates of Mary Immaculate, the Sisters of St. Joseph of Orange, the Libra Fund and the Marianist Province | 1 | 1
Miscellaneous |
|||
| SNET Retirees Association, Inc. and Jane Banfield | 1 | 1
Compensation |
|||
| Social Justice Fund Northwest | 1 | 1
Employment Rights |
|||
| The Calvert Social Index Fund, The Calvert VP S&P 500 Index Portfolio and The Calvert Equity Income Fund | 1 | 1
Environmental |
|||
| The Church Pension Fund and The Domestic and Foreign Missionary Society of the Episcopal Church | 1 | 1
Lobbying |
|||
| The Firefighters' Pension System of the City of Kansas City, Missouri, Trust | 1 | 1
Compensation |
|||
| The National Center for Public Policy Research | 4 | 2
Miscellaneous (2) |
1
Environmental |
1
Political Spending |
|
| The Needmor Fund, The Russell Family Foundation, Everence Financial on behalf of the Praxis Value Index Fund, Zevin Asset Management, LLC on behalf of the Janet Axelrod 1997 Revocable Trust, Ellen D. Goldberg, lzetta Smith and Anne B. Lawson | 1 | 1
Environmental |
|||
| The Sisters of St. Francis of Dubuque Iowa | 1 | 1
Environmental |
|||
| The Sustainability Group of Loring, Wolcott & Coolidge | 1 | 1
Independent Chair |
|||
| Theodore Bernat | 1 | 1
Capital Structure |
|||
| Thomas Strobhar | 1 | 1
Human Rights |
|||
| Trowel Trades S&P 500 Index Fund | 1 | 1
Compensation - Gross-ups |
|||
| UA W Retiree Medical Benefits Trust, Mercy Investment Services, Inc. and Catholic Health East | 1 | 1
Human Rights |
|||
| UAW Retiree Medical Benefits Trust | 1 | 1
Human Rights |
|||
| Unitarian Universalist Service Committee, The Needmor Fund | 1 | 1
Lobbying |
|||
| United Brotherhood of Carpenters Pension Fund | 4 | 2
Majority Voting (2) |
1
Majority Voting |
1
Majority Voting |
|
| William C. Wardlaw, III; the Board of Pensions of the Presbyterian Church (USA); the Benedictine Sisters of Boerne, Texas; the Benedictine Sisters of Mount St. Scholastica; the Benedictine Sisters of Virginia; Providence Trust and the Sisters of Charit | 1 | 1
Human Rights |
|||
| William J. Freeda | 1 | 1
Compensation |
|||
| William Steiner | 8 | 1
Accelerated Vesting |
6
Accelerated Vesting (1) Declassify the Board (1) Written Consent (4) |
1
Accelerated Vesting |
|
| Grand Total | 167 | 84 | 41 | 41 | 1 |
| Earlier No-Action Letters | |||||
| Company | Filing Date | Proposal Category | Proponent | Status | SEC Filing |
| AutoNation, Inc. (AN) | February 19, 2014 | Equity Compensation | International Brotherhood of Electrical Workers Pension Benefit Fund | Proponent Withdraws | NO ACT |
| Bank of America Corporation (BAC) | February 19, 2014 | Compensation | New York State Common Retirement Fund | SEC Accepts | NO ACT |
| Boston Properties, Inc. (BXP) | February 19, 2014 | Compensation - CEO Pay Ratio | Amalgamated Bank's LongView Large Cap 500 Index Fund | Proponent Withdraws | NO ACT |
| CF Industries Holdings, Inc. (CF) | February 19, 2014 | Call Special Meeting | John Chevedden | SEC Accepts | NO ACT |
| CME Group Inc. (CME) | February 19, 2014 | Environmental | The Calvert Social Index Fund, The Calvert VP S&P 500 Index Portfolio and The Calvert Equity Income Fund | Proponent Withdraws | NO ACT |
| CVS Caremark Corporation (CVS) | February 19, 2014 | Miscellaneous | The National Center for Public Policy Research | SEC Accepts | NO ACT |
| Dominion Resources, Inc. (D) | February 19, 2014 | Environmental | Elena Baum | SEC Accepts | NO ACT |
| Quest Diagnostics Incorporated (DGX) | February 19, 2014 | Call Special Meeting | John Chevedden | SEC Accepts | NO ACT |
| AT&T Inc. (T) | February 19, 2014 | Human Rights | Thomas Strobhar | SEC Accepts | NO ACT |
| Bank of America Corporation (BAC) | February 18, 2014 | Miscellaneous | Missionary Oblates of Mary Immaculate, the Sisters of St. Francis of Philadelphia, the American Baptist Home Mission Society, Neva Goodwin, the Sisters of St. Dominic of Caldwell New Jersey, the Needmor Fund and the Sisters of Charity of Saint Elizabeth | Proponent Withdraws | NO ACT |
| Pfizer Inc. (PFE) | February 18, 2014 | Miscellaneous | The National Center for Public Policy Research | SEC Accepts | NO ACT |
| Dominion Resources, Inc. (D) | February 14, 2014 | Miscellaneous | Joyce Loving | SEC Accepts | NO ACT |
| Entergy Corporation (ETR) | February 14, 2014 | Environmental | Park Foundation | SEC Accepts | NO ACT |
| The GEO Group, Inc. (GEO) | February 14, 2014 | Miscellaneous | Alex Friedmann | SEC Accepts | NO ACT |
| Mondelez International, Inc. (MDLZ) | February 14, 2014 | Compensation | The Firefighters' Pension System of the City of Kansas City, Missouri, Trust | SEC Accepts | NO ACT |
| Wells Fargo & Company (WFC) | February 14, 2014 | Compensation | New York State Common Retirement Fund | SEC Accepts | NO ACT |
| Citigroup Inc. (C) | February 12, 2014 | Lobbying | CtW Investment Group | SEC Accepts | NO ACT |
| The Goldman Sachs Group, Inc. (GS) | February 12, 2014 | Human Rights | Jing Zhao | SEC Accepts | NO ACT |
| Nabors Industries Ltd. (NBR) | February 12, 2014 | Independent Chair | City of Philadelphia Public Employees Retirement System | Proponent Withdraws | NO ACT |
| Wal-Mart Stores, Inc. (WMT) | February 12, 2014 | Political Spending | The National Center for Public Policy Research | Proponent Withdraws | NO ACT |
| Dominion Resources, Inc. (D) | February 11, 2014 | Environmental | Christopher S. McElroy Irrev Trust U/A | SEC Denies | NO ACT |
| Mondelez International Inc. (MDLZ) | February 11, 2014 | Compensation - CEO Pay Ratio | Qube Investment Management Inc. | SEC Accepts | NO ACT |
| The NASDAQ OMX Group, Inc. (NDAQ) | February 11, 2014 | Miscellaneous | Calvert Social Index Fund and the Calvert VP S&P 500 Index Portfolio | Proponent Withdraws | NO ACT |
| Wells Fargo & Company (WFC) | February 11, 2014 | Miscellaneous | Christian Brothers Investment Services, Inc.; the Benedictine Sisters of Mount St. Scholastica; The Granary Foundation; the Board of Pensions of the Presbyterian Church (USA); Providence Trust; the School Sisters of Notre Dame, Central Pacific Province; C | Proponent Withdraws | NO ACT |
| ACE Limited (ACE) | February 10, 2014 | Director Independence | Qube Investment Management Inc. | SEC Accepts | NO ACT |
| Dominion Resources, Inc. (D) | February 10, 2014 | Environmental | Pamela Morgan | SEC Denies | NO ACT |
| Harley-Davidson, Inc. (HOG) | February 10, 2014 | Majority Voting | United Brotherhood of Carpenters Pension Fund | SEC Denies | NO ACT |
| Johnson & Johnson (JNJ) | February 10, 2014 | Written Consent | Myra K. Young | SEC Accepts | NO ACT |
| Johnson & Johnson (JNJ) | February 10, 2014 | Political Spending | NorthStar Asset Management, Inc. Funded Pension Plan | SEC Accepts | NO ACT |
| Moody's Corporation (MCO) | February 10, 2014 | Miscellaneous | Calvert Social Index Fund and the Calvert VP S&P 500 Index Portfolio | SEC Accepts | NO ACT |
| Exxon Mobil Corporation (XOM) | February 10, 2014 | Environmental | Province of St. Joseph of the Capuchin Order | Proponent Withdraws | NO ACT |
| Bank of America Corporation (BAC) | February 7, 2014 | Capital Structure | Theodore Bernat | SEC Accepts | NO ACT |
| The Dow Chemical Company (DOW) | February 7, 2014 | Written Consent | Kenneth Steiner | SEC Denies | NO ACT |
| 3M Company (MMM) | February 7, 2014 | Compensation - CEO Pay Ratio | Qube Investment Management Inc. | SEC Accepts | NO ACT |
| Verizon Communications Inc. (VZ) | February 7, 2014 | Miscellaneous | Nathan Cummings Foundation | SEC Denies | NO ACT |
| General Electric Company (GE) | February 6, 2014 | Environmental | GE Stockholders' Alliance, the Leo A. Drey Revocable Trust and Olga P. Strickland | SEC Accepts | NO ACT |
| International Business Machines Corporation (IBM) | February 6, 2014 | Human Rights | Peter W. Lindner | SEC Accepts | NO ACT |
| The NASDAQ OMX Group, Inc. (NDAQ) | February 6, 2014 | Call Special Meeting | Kenneth Steiner | Proponent Withdraws | NO ACT |
| United Parcel Service, Inc. (UPS) | February 6, 2014 | Voting Rules | John Chevedden | SEC Denies | NO ACT |
| General Electric Company (GE) | February 5, 2014 | Mergers and Acquisitions | Robert Fredrich | SEC Denies | NO ACT |
| General Electric Company (GE) | February 5, 2014 | Miscellaneous | Neal Renn | SEC Accepts | NO ACT |
| Verizon Communications Inc. (VZ) | February 5, 2014 | Equity Compensation | International Brotherhood of Electrical Workers Pension Benefit Fund | SEC Accepts | NO ACT |
| Wells Fargo & Company (WFC) | February 5, 2014 | Miscellaneous | Sisters of St. Francis of Philadelphia, The Needmor Fund, the Missionary Oblates of Mary Immaculate, the Sisters of St. Joseph of Orange, the Libra Fund and the Marianist Province | Proponent Withdraws | NO ACT |
| DST Systems, Inc. (DST) | February 4, 2014 | Independent Chair | Connecticut Retirement Plans and Trust Funds | SEC Accepts | NO ACT |
| Fifth Third Bancorp (FITB) | February 4, 2014 | Political Spending | Congregation of the Sisters of Charity of the Incarnate Word, San Antonio and First Affirmative Financial Network, LLC. | SEC Accepts | NO ACT |
| Southwestern Energy Company (SWN) | February 3, 2014 | Lobbying | The Church Pension Fund and The Domestic and Foreign Missionary Society of the Episcopal Church | Proponent Withdraws | NO ACT |
| Verizon Communications Inc. (VZ) | February 3, 2014 | Miscellaneous | Neil Maizlish | Proponent Withdraws | NO ACT |
If you are interested in the No-Action requests acted upon by the SEC prior to February, 2014 please contact Steve Walsh at 212 656-4519 or swalsh@nyx.com.
Thank You
NYSE Governance Services Team
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